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`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
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`Apple Inc.,
`Petitioner,
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`v.
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`IMMERSION CORPORATION,
`Patent Owner.
`___________________
`
`Case IPR2017-01310
`Patent No. 8,749,507
`___________________
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`
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`DECLARATION OF DANIEL WIGDOR, PH.D.
`IN SUPPORT OF IMMERSION CORPORATION’S
`PATENT OWNER PRELIMINARY RESPONSE
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`I, Daniel Wigdor, declare as follows:
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`DECLARATION OF DANIEL WIGDOR
`Case IPR2017-01310
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`I.
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`INTRODUCTION
`1. My name is Daniel Wigdor. I have been engaged by Immersion
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`Corporation (“Immersion”) as an expert in connection with matters raised in the
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`Petition for Inter Partes Review (“Petition”) of U.S. Patent No. 8,749,507 (the
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`“‘507 patent”) filed by Apple Inc. (“Petitioner”).
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`2.
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`This declaration is based on the information currently available to me.
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`To the extent that additional information becomes available, I reserve the right to
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`continue my investigation and study, which may include a review of documents
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`and information that may be produced, as well as testimony from depositions that
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`have not yet been taken.
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`II. QUALIFICATIONS AND EXPERIENCE
`3.
`A detailed description of my professional qualifications, including a
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`list of publications, awards, and professional activities, is contained in my
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`curriculum vitae, a copy of which is attached as Exhibit 2002.
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`4.
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`I am an Associate Professor of Computer Science at the University of
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`Toronto, where I have appointments in the Department of Computer Science, the
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`Department of Mathematical and Computational Sciences, as well as in the
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`Department of Mechanical and Industrial Engineering. I am also the co-director of
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`the Dynamic Graphics Project (DGP) at the University of Toronto. I am also a
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`Visiting Associate Professor of computer science at Cornell University. I have
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`DECLARATION OF DANIEL WIGDOR
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`several years of industry experience in user interface and Human-Computer
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`Interaction (HCI) as a User Experience Architect at Microsoft. I was also a
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`cofounder of Iota Wireless, a start-up dedicated to text-entry techniques for mobile
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`phones, and of Tactual Labs, a startup focused on commercializing my research in
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`mobile device input sensing and architectures. At the DGP, I work in the area of
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`Human-Computer Interaction (HCI), specializing in the design and development of
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`platforms for modern, post-WIMP (“windows, icons, menus, pointer”) user
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`interfaces. Researchers in this field focus on developing effective and efficient
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`user interfaces without the use of traditional WIMP or Windows-based interface
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`elements. These require the development of new computer software and hardware,
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`with dual foci on both graphical and physical user interface technologies. My
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`approach is to utilize interdisciplinary research methods to bring new insights in
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`perceptual, cognitive, and motor abilities to the development of intuitive and useful
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`technology artefacts, as well as to the development of user interface technology
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`architectures and development methods. Over the last five years, one of my major
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`projects has been the creation of immersive experiences simulating physical
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`feelings of interactions with real world objects. This has included the development
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`of methods for the detection of gestures input to sensors such as 3D cameras,
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`traditional computer vision-based tools, and capacitive touch screens, and, in
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`response to those gestures, generating haptic effects, using technologies such as
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`vibro-motors, pneumatic shape-changing objects, or robotics.
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`5.
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`In 2002, I received a Bachelor’s degree (Hons) from the University of
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`Toronto with a specialization in Human Computer Interaction, including a major-
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`equivalent in computer science and a minor-equivalent in psychology and
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`sociology.
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`6.
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`In 2004, I received a Master of Science degree in Computer Science
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`from the University of Toronto. My work focused on mobile phone user
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`interfaces, as well as other gesture-based systems.
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`7.
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`In 2008, I received a Ph.D. in Computer Science from the University
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`of Toronto in 2008. My Ph.D. work was focused on the design and
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`implementation of capacitive gesture-based interactive systems, especially large
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`table-sized touchscreens, and their integration into large control centers. Among
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`other things, this required the development of gesture recognition methodologies
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`and software.
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`8.
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`In 2011-2012 I was an Associate of the School of Engineering and
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`Applied Sciences at Harvard University, working as a member of the Scientists’
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`Discovery Room (SDR) Lab at the School of Engineering and Applied Sciences
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`(SEAS). At the SDR Lab at Harvard, I was responsible for supervising the
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`research projects of post-doctoral fellows in collaboration with the lab director. I
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`have taught classes at the University of Washington and the University of Toronto,
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`in both computer science and computer engineering departments. Topics include
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`software design, algorithms, formal algorithm analysis, data structures, and human
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`computer interaction, including the design of user interfaces for mobile phones and
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`the design, prototyping, and construction of hardware devices.
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`9.
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`At Microsoft, I served over half a dozen different roles. As the
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`architect of user experiences of Natural User Interfaces at Microsoft’s
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`Entertainment & Devices division, I was responsible for ensuring high-quality and
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`exciting user experiences in platform and partner applications, such as Microsoft
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`Surface. I also served as Microsoft’s company-wide expert on Natural User
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`Interfaces, which required that I give educational sessions for the company on the
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`design of gesture-based systems. It also meant that I routinely consulted on the
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`design of both software and hardware products focused on touch and gesture-based
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`systems, such as Windows 8, Windows Phone 7, the Microsoft Kinect gesture-
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`based gaming system, and many others. My work in Windows Phone included
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`assisting with the development of haptic feedback mechanisms in the operating
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`system.
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`10.
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`I hold Hon., B.Sc., M.S., and Ph.D. degrees in computer science, and
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`have published extensively, with about 65 peer-reviewed technical publications. I
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`have also contributed four textbook chapters on HCI, and co-authored “Brave NUI
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`World: Designing Natural User Interfaces for Touch and Gesture,” the first
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`practical book for the design of touch and gesture interfaces, in 2011, which has
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`since been translated into Chinese and Korean. I have given over 80 invited talks,
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`including 4 keynote lectures. I have won numerous awards for my research,
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`including the prestigious Early Research Award from the Ontario Ministry of
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`Research and Innovation (2014) and an Alfred P. Sloan Research Fellowship in
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`Computer Science (2015).
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`11.
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`I have worked as an expert in several legal matters as a consulting
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`expert and an expert witness. I have written expert reports, have had my
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`deposition taken, and have provided trial testimony. Attached as Exhibit 2002 is
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`my curriculum vitae, which includes a complete list of my qualifications and
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`includes a list of matters in which I have provided expert testimony, either at
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`deposition or at trial.
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`12.
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`I am being compensated by Immersion for my time spent in
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`connection with this matter at a rate of $525 per hour. My compensation is not
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`contingent upon the substance of my opinions, the content of this declaration or
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`any testimony I may provide, or the outcome of the inter partes review or any
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`other proceeding.
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`III. MATERIALS REVIEWED AND CONSIDERED
`13. My opinions expressed in this declaration are based on the Petition
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`and exhibits cited in the Petition, and other documents and materials identified in
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`this declaration, including the ‘507 patent and its prosecution history, the prior art
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`references and materials discussed in this declaration, and any other references
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`specifically identified in this declaration.
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`IV. SUMMARY OF OPINIONS
`14. The Petition raises one ground of invalidity. Petition at 3. The
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`Petitioner states that claims 1-18 of the ‘507 patent are rendered obvious by U.S.
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`Patent No. 6,590,568 (“Astala”) in view of U.S. Patent Application Publication No.
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`2002/0033795 (“Shahoian”). Id.
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`15. Based on studying the Petition and the exhibits cited in the Petition as
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`well as other documents, it is my opinion that Astala in view of Shahoian does not
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`render obvious any of claims 1-18 of the ‘507 patent.
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`V. LEGAL PRINCIPLES
`A. Obviousness
`16.
`It is my understanding that a claim is not patentable under 35 U.S.C. §
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`103 if the claimed subject matter as a whole would have been obvious to a person
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`of ordinary skill in the art at the time of the alleged invention. I understand that
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`obviousness is a question of law based on underlying factual issues. I also
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`understand that an obviousness analysis takes into account the scope and content of
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`the prior art, the differences between the claimed subject matter and the prior art,
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`the level of ordinary skill in the art at the time of the invention, and the existence
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`of secondary consideration such as commercial success or long-felt but unresolved
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`needs.
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`VI. OVERVIEW OF THE ‘507 PATENT
`17. The ‘507 patent is entitled “Systems and Methods for Adaptive
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`Interpretation of Input from a Touch-sensitive Input Device.” The patent arose out
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`of Immersion’s work developing improved ways to interpret touch inputs from
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`different users of a device, such as a touchscreen on a cell phone. Because of
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`factors such as physical differences between users, different angles of finger
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`contacts, different pressures applied by different users or between different
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`touches, or finger movement across the touch surface during a press, it may be
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`difficult to determine the user’s intent. Ex. 1101 at 1:55-65. The ‘507 patent
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`addresses these difficulties by determining a gesture using additional information
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`about a touch other than just position or pressure. For example, a press is
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`determined if the “pressure is greater than a pressure threshold,” “the change in
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`pressure is greater than a change in pressure threshold,” and “a first interval has
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`elapsed.” Id. cl. 1. Using these criteria, the system can better determine the user’s
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`intended gesture and provide haptic feedback in response. Id. 4:47-63.
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`VII. LEVEL OF ORDINARY SKILL IN THE ART
`18.
`I understand that the specification and claims must be read through
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`the eyes of a person of ordinary skill in the art (“POSITA”) at the time of the
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`invention.
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`19. Based on my background and experience, a POSITA in the field of
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`the ‘507 patent would have a Bachelor’s degree in mechanical or electrical
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`engineering (or other engineering discipline), computer science, or at least two
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`years of experience working with human machine interface systems, graphical user
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`interfaces, haptic feedback systems, or mobile devices, or equivalent embedded
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`systems.
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`20.
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`I have reviewed the level of ordinary skill in the art proposed by
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`Petitioner’s expert, Dr. Cockburn. See Ex. 1110 at ¶ 45. Although I do not agree
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`with Dr. Cockburn on this point, if that level of skill were applied, it would not
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`change my opinions regarding validity set forth in this declaration.
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`VIII. CLAIM CONSTRUCTION
`21.
`I have been asked
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`to opine on Petitioner’s proposed claim
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`construction of the term “pseudo pressure” in claims 2, 10, and 15 of the ‘507
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`patent. I understand that, during inter partes review, a patent claim shall be given
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`“its broadest reasonable construction in light of the specification of the patent in
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`which it appears.” I understand that Petitioner argues that “pseudo pressure”
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`should be interpreted to include “at least all indirect measures of pressure” and that
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`any measure of pressure using “capacitance” or “resistance” is necessarily an
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`indirect measure of pressure, or “pseudo pressure.” See Petition at 15-16, 45.
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`22.
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`In my opinion, Petitioner’s interpretation is not reasonable in light of
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`the disclosure of the ‘507 patent and the knowledge of a POSITA at the time of the
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`invention. For example, claims 2, 10, and 15 of the ‘507 patent distinguish
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`between “actual pressure” and “pseudo pressure.” Ex. 1101 at cls. 2, 10, 15
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`(“wherein the contact data comprises an actual pressure and a pseudo pressure”).
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`Petitioner’s interpretation of “pseudo pressure” is so broad as to render the claim
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`term “actual pressure” meaningless. As a specific example, it was well known at
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`the time of the ‘507 patent invention that actual pressure could be measured using
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`resistive or capacitive sensors. A common technique for measuring the actual
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`pressure applied to a surface was to place a parallel-plate capacitor under the
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`surface and measure the change in capacitance caused by the downward deflection
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`of the surface as pressure is applied. U.S. Patent No. 4,555,952 to Jenkins (Ex.
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`2009) describes pressure sensors of this type as being known in the art as early as
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`1985. See Ex. 2009 at 1:10-20 (“Pressure sensors known in the prior art generally
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`teach a pressure or force responsive diaphragm forming one plate or electrode of a
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`capacitor. This electrode or capacitor plate is subject to deformation, the extent of
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`which is compared to a second electrode means or capacitive plate that is not
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`displaced.”). A POSITA would not consider this well-known pressure-sensing
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`technique to measure “pseudo pressure,” as Petitioner’s interpretation would
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`suggest.
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`23.
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`In my opinion, the broadest reasonable interpretation of “pseudo
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`pressure” in the ‘507 patent is “a measure of the area of the screen contacted by an
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`object.” The specification explains that this measure of contact area, or “pseudo
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`pressure,” may be useful in determining how much pressure the user is applying to
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`the screen, because a finger pressing heavily will tend to flatten out and cover more
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`surface area. See Ex. 1101 at 3:24-28 (“[I]f a user presses heavily against the
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`touchpad 102 with a fleshy part of the finger, the amount of touchpad 102 area
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`covered by the finger is greater than when the same part of the finger is touching
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`lightly.”) (emphasis added). This interpretation covers possible implementations
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`of “pseudo pressure” using the full range of touchpad technologies described in the
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`‘507 patent, including capacitive and resistive sensors, provided they actually use
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`the contact area-based “pseudo pressure” measurement technique disclosed in the
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`‘507 patent specification. Ex. 1101 at 2:55-61 (“The touchpad 102 shown in FIG.
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`1 utilizes capacitance, however, an embodiment of the present invention may be
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`implemented in conjunction with any touch-sensitive input device, including
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`resistive and membrane-switch touchpads.”).
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`IX. ASTALA AND SHAHOIAN DO NOT RENDER OBVIOUS THE
`CLAIMS OF THE ‘507 PATENT
`24.
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`In general, the ‘507 patent teaches techniques for determining whether
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`a user’s contact with a touchscreen is intended as a press, as opposed to an
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`accidental touch or some other gesture. For example, the ‘507 patent teaches
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`determining a press if the user applies pressure greater than a pressure threshold,
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`the change in pressure is greater than a change in pressure threshold, and a first
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`interval has elapsed. Ex. 1101 at cl. 1. Astala and Shahoian do not teach
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`determining a press. Astala describes detecting certain touch inputs, but even still
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`does not teach detecting touch inputs using the technique described in the ‘507
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`patent for determining a press. For example, neither Astala nor Shahoian teach
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`determining a press based on a change in pressure being greater than a change in
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`pressure threshold.
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`25. Unlike the ‘507 patent, Astala determines touch inputs using a simple
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`approach derived from a traditional “mouse click” gesture – looking only at the
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`pressure applied by the user for a period of time. Ex. 1103 at 2:32-38 (“For
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`example, pressing a selection point for a first predetermined time period may
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`correspond to single clicking the left button on a mouse.”).
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`26. Astala uses this technique to detect the two touch inputs that begin
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`and end a “drag-and-drop” sequence that the user may perform on a touchscreen
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`computer system. Ex. 1103 at 2:11-14, Figs. 1-2; 3:30-34. For example, a file can
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`be dragged and dropped into a directory folder. Astala describes how the user can
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`“drag and drop” displayed items by proceeding through three steps: (1) the user
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`applies pressure to an icon to select it; (2) the user reduces the applied pressure and
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`drags the icon across the screen; and (3) the user applies pressure a second time, on
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`the destination for the icon. Ex. 1103 at 9:3-65.
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`27. Astala never discloses or suggests determining a touch input or press
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`based on a change in pressure or change in pressure threshold. Astala expressly
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`teaches that both the “first” and “second” touch inputs of its drag-and-drop
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`sequence are determined based only on the pressure and duration of the touch. Ex.
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`1103 at 9:27-30 (“At step 710, a determination is made that the value of the
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`pressure z of touch input 732 is greater than a predetermined value Za over the
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`period of time.”), 9:50-53 (“At step 716, a second touch input is detected by
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`determining that the value of the pressure z of the object on the touch screen 70 is
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`greater than a predetermined pressure value zB (which may be equal to zA) over a
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`period of time.”). Every single reference in Astala to determining a touch input of
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`any kind involves at most only those two criteria—pressure and time. Ex. 1103 at
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`9:27-30 (first touch input), 9:50-53 (second touch input), cl. 14 (two touch inputs
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`described in Claim 14).
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`28.
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`I understand that Petitioner contends that a reduction (change) in
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`pressure is required as part of the first touch input of the drag-and-drop sequence.
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`Petition at 33-34. I disagree. Astala only looks at change in pressure after the first
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`touch input has been determined based on pressure and time. The change in
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`pressure requirement is used to determine whether the user intends to initiate the
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`“dragging” mode, where the selected icon may be dragged across the touch screen
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`to another location (such as a destination folder). In other words, after the user has
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`“selected” an icon by performing the first touch input (based on pressure and time),
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`then the user may initiate a “drag” by reducing the applied pressure on the selected
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`icon. Ex. 1103 at Fig. 6(a) (step 712), 9:40-56. This is represented in Astala’s
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`flowchart figure by step 712. Id.
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`29. Once the user has initiated the “drag” in step 712 by reducing the
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`applied pressure, the user may then proceed to drag the selected icon around the
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`touchscreen by sliding his or her finger across the surface. Ex. 1103 at 9:40-56.
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`The selected icon is then “dragged across the face of the touch screen 70 at the
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`reduced pressure z,” i.e., following the dragging movement of the user’s finger.
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`Ex. 1103 at 9:40-42, Fig. 6b (illustrating “drag path 734” for the selected icon).
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`This is represented in Astala’s flowchart by step 714, “FOLLOW DRAG.” Ex.
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`1103 at Fig. 6a (step 714). The dragging process ends when the user performs a
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`second touch input to “drop” the icon on a destination. As with the first touch
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`input, Astala clearly explains that this second touch input is determined based only
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`on pressure and time. Ex. 1103 at 9:50-55 (“At step 716, a second touch input is
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`detected by determining that the value of the pressure z of the object on the touch
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`screen 70 is greater than a predetermined pressure value zB (which may be equal
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`to zA) over a period of time t2 of the object touching the touch screen 70 which is
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`greater than a predetermined period of time tB.”), Fig. 6a (step 716).
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`30. A POSITA would recognize that any time a user is touching a
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`touchscreen with variable amounts of pressure, such as when pushing down on a
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`displayed icon, the “x,y position” values reported by the touchscreen will be
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`constantly varying because as the finger pushes down it moves slightly on the
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`screen. If the “drag” step in Astala were initiated solely by a change in x,y
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`position of the finger, as I understand Petitioner contends, the result would be the
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`system switching into “drag mode” and moving the displayed icon while the user is
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`in the middle of trying to push on the icon to select it. This is why Astala instead
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`describes using a reduction in pressure as a delimiter for the beginning of the
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`“drag” step, and describes detecting this reduction in pressure in step 712, after the
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`first touch input has been detected in step 710.
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`31. Astala’s claim 14 describes an alternative version of the “drag-and-
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`drop” gesture where the user can forgo the “dragging” step and simply apply
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`pressure to an icon and then its desired destination. For example, in the claim 14
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`embodiment a user applies pressure to an icon to select it and then can, for
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`example, lift his or her finger entirely off of the screen (without dragging) and then
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`apply pressure again on the target destination. Notably, because claim 14 contains
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`no description of the “dragging” step, claim 14 also contains no description of
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`detecting a reduction or change in pressure (step 712), because that step is
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`unnecessary in an embodiment with no “dragging” step.
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`32. A POSITA reading claim 14 and comparing it to the other claims
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`(such as claim 1) and the embodiment described in the specification would
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`recognize that, in Astala, the detection of a change in pressure is directly tied to
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`detecting a “dragging” movement across the screen, such that when the “dragging”
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`is omitted, the detection of change in pressure is also omitted. In other words, the
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`detection of the change in pressure associated with the drag is totally independent
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`of Astala’s detection of the first and second touch inputs (which remain in claim
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`14).
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`33.
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`I understand that Petitioner contends that it would have been obvious
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`for a POSITA to modify Astala’s system to arrive at the ‘507 patent invention.
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`Petition at 35-36. I disagree. For example, Petitioner’s suggestion that the “drag”
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`could instead be detected “based on finger movement,” see Petition at 36, would
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`not have been obvious to a POSITA. A POSITA would have recognized that
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`detecting the beginning of a “drag” movement based only on finger movement
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`would result in problems because some amount of finger movement is inevitably
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`DECLARATION OF DANIEL WIGDOR
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`detected during the application of pressure to a touchscreen. Such a system would
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`prematurely detect the initiation of a “drag” while the user was still attempting to
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`press, and so a POSITA would avoid modifying Astala to determine the “drag” in
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`this manner.
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`34. Furthermore, as I discussed previously, Astala’s “drag-and-drop”
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`gesture includes both a first touch input (to select an icon) and a second touch input
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`(to drop the icon at its destination). Astala describes both the first and second
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`touch inputs as being performed in the same way: by applying sufficient pressure
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`for a sufficient amount of time. A POSITA would not be motivated to modify
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`Astala’s first touch input to require a reduction in pressure as an additional
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`limitation, because it would be confusing for the user if the first touch input
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`required a reduction in pressure to perform when the second touch input had no
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`such requirement. A POSITA would generally avoid modifying a system in a way
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`that created confusion and inconsistency for the user regarding the type of physical
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`actions required to perform functions such as a touch input or press.
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`35. Additionally, as I discussed previously, when Astala describes an
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`embodiment of its invention without the “dragging” step, in claim 14, Astala also
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`drops all references to detecting changes in pressure. Ex. 1103 at cl. 14. In this
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`regard, Astala clearly teaches a POSITA that “change in pressure” is associated
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`DECLARATION OF DANIEL WIGDOR
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`with dragging, not pressing.
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`36. The claims of the ‘507 patent also contain the limitation “responsive
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`to determining the gesture, outputting the haptic effect.” Ex. 1103 at cls. 1, 9, 14.
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`Astala contains no disclosure whatsoever of outputting haptic effects and its
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`disclosed system has no haptic capability at all, so it cannot meet this limitation.
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`37. The ‘507 patent claims include the requirement “responsive to
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`determining the gesture, outputting a haptic effect.” Ex. 1101 at cls. 1, 9, 14. I
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`understand that Petitioner contends that this “gesture” is disclosed by the “drag-
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`and-drop” sequence in Astala. Petition at 38. Therefore, the “haptic effect” output
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`by the combination of Astala and Shahoian would need to be output “responsive
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`to” determining the drag-and-drop gesture.
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`38. Astala contains no disclosure regarding haptics. I understand that
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`Petitioner relies on Shahoian’s disclosure of haptic feedback and contends that a
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`POSITA would be motivated to incorporate the teachings of Shahoian into Astala.
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`Petition at 38. Shahoian describes providing a vibration while the user is in a
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`“drag mode,” to let the user know that the “drag mode” is currently active. Ex.
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`1104 at ¶ 189 (“When the user is in such a drag mode, a vibration or other haptic
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`sensation can be output to indicate to the user that this mode is active.”).
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`DECLARATION OF DANIEL WIGDOR
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`39. Even if Shahoian were combined with Astala, as Petitioner contends,
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`this combination would not output a haptic effect “responsive to” the drag-and-
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`drop gesture of Astala. At most, the combined system would vibrate while the user
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`was dragging his or her finger across the screen (i.e., “when the user is in such a
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`drag mode”), before the user has finished the drag-and-drop gesture by “dropping”
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`the icon on a destination location.
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`40. Astala and Shahoian also fail to disclose the “pseudo pressure”
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`limitation in claims 2, 10, and 15 of the ‘507 patent. These claims include the
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`limitation “wherein the contact data comprises an actual pressure and a pseudo
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`pressure.” Ex. 1101 at cls. 2, 10, 15. Neither Astala nor Shahoian disclose contact
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`data comprising a pseudo pressure.
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`41.
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`I understand that Petitioner argues that Shahoian “discloses capacitive
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`sensors in the context of detecting pressure,” because it discloses “capacitive
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`touchpads that do not require significant pressure.” Petition at 45. I disagree.
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`Shahoian is not discussing capacitive touchpads in the context of pressure
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`detection. Shahoian simply states that a capacitive touchpad is capable of
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`measuring the location of a user’s touch even when the user is pressing lightly (i.e.,
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`without significant pressure). Ex. 1104 at ¶ 41 (“Capacitive touchpads typically
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`sense the location of an object on or near the surface of the touchpads . . .”)
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`(emphasis added). Shahoian never discloses or suggests using capacitive sensors
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`DECLARATION OF DANIEL WIGDOR
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`to actually measure pressure (directly or indirectly).
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`42.
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`I understand that Petitioner argues that Shahoian discloses a pseudo
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`pressure because it discloses a “resistive” pressure-sensitive touchpad. Petition at
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`45. I disagree. As I discussed previously regarding claim construction, the fact
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`that a sensor uses resistance does not mean that it is necessarily measuring “pseudo
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`pressure.” Electrical resistance is simply the degree to which a conductor opposes
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`an electric current through that conductor. Actual pressure sensors can measure
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`changes in resistance in order to directly determine how much actual pressure a
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`user is applying to a surface. Similarly, a pseudo pressure sensor can measure
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`changes in resistance in order to determine the area of the screen being contacted
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`by the user’s finger, which could be indirectly correlated with applied pressure.
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`The fact that a sensor uses resistance is not dispositive, one way or another, of
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`whether the sensor is an actual pressure sensor or pseudo pressure sensor.
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`Moreover, Shahoian describes its sensors as measuring actual pressure directly, not
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`indirectly. See Ex. 1104 at ¶ 188 (what is “sensed” is “the amount of pressure the
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`user is exerting on the touchpad”). Shahoian never discloses or suggests that its
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`touchpad measures pressure indirectly, such as via a “pseudo pressure” technique
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`based on contact area.
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`DECLARATION OF DANIEL WIGDOR
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`43.
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`I understand that Petitioner argues that Shahoian discloses a pseudo
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`pressure because it includes a “palm check” feature, which “computes the contact
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`area made by the conductive object (finger, palm, arm, etc.).” Petition at 46. I
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`disagree. Shahoian’s “palm check” feature is totally unrelated to the determination
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`of pressure based on contact data. Shahoian teaches that if a large contact area
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`(associated with the user accidentally touching with a palm) is encountered, the
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`system should “ignore input that is determined to be provided by a user’s palm.”
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`Ex. 1104 at ¶ 51. In other words, Shahoian only uses contact area to determine
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`whether “the contact is rejected.” Id. Shahoian’s disclosure would not lead a
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`POSITA to use contact area as a pseudo pressure as claimed in the ‘507 patent.
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`44.
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`I hereby declare that all statements made herein of my own
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`knowledge are true and that all statements made on information and belief are
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`believed to be true; and further that these statements were made with the
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`knowledge that willful false statements and the like so made are punishable by fine
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`or imprisonment, or both, under Section 1001 of the Title 18 of the United States
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`Code.
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`Executed on the 9th day of August 2017.
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`___________________________
`Professor Daniel Wigdor,
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